As I have mentioned a few times, there is a substantial difference between a Safe Work Practice design to make OSHA happy and one that functions as a “management system” for the risk the “program” is trying to control.  Far too many “safety programs” are simply regurgitating the OSHA standards they intend to comply with. Sometimes, we come across a cut-and-paste...

The respondent owns and operates a single-site aerosol can manufacturing facility that uses, stores, and handles Isobutane (CAS# 85-28-5), a regulated substance, at the Facility in amounts over the threshold quantity for Isobutane of 10,000 lbs. The facility used, stored, and handled Butane (CAS# 106-97-8), a regulated substance, at the Facility in amounts over the threshold quantity for Butane of...

The following are my tips to ensure PRCS are properly ventilated when necessary.  Far too often, ventilation is nothing more than a “nice effort,” which can lead to disastrous results.  So, in my time in safety at petrochemical and semiconductor facilities, the safety team managed the ventilation equipment (blowers and flexible ductwork). Still, the entry supervisor was responsible...

I was working on another PRCS Entry program this week and thought I would offer some tidbits I include in my programs regarding: Space Isolation Atmospheric Monitoring My programs are lengthy and are intended to include every aspect of managing the risks associated with working around and inside PRCSs. SPACE ISOLATION ALL connections to a confined space that can convey a hazard to the space...

If you really want to get a feel for the culture around safety, STOP with the surveys and get with today’s technology Three of my five bosses throughout my career all had this same practice, which is far more telling than a “survey.” And with today’s technology, such as cameras and drones, there is a far better way to gauge the “safety mindset” of our workforce. It works like this… Hire a...

“… an attitude of frustration or an internal state of distress can certainly influence driving behaviors, and vice versa. Indeed, internal (unobserved) personal states of mind continually influence observable behaviors, while changes in observable behaviors continually affect changes in person states or attitudes. Thus, it is possible to “think a person into safe behaviors” (through education,...

In process safety, we spend a lot of time discussing the PRIMARY containment systems; however, our secondary containment systems play a vital role in our PROTECTION and MITIGATION layers of protection. Of course, we want to keep the tiger in its cage, but we also need to be prepared for the day it gets loose, and this is where our secondary containment systems come into play. With all that said, let’s...

It never ceases to amaze me how businesses will cut corners in fundamental safety protections. Recently, I came across fire extinguishers that were not “approved” by a Nationally Recognized Testing Laboratory (NRTL). This was discovered during a 5-year REVAL PHA after the facility suffered a failure of one of its extinguishers that caused damage to some PSM/RMP piping. The investigation...

Following the investigation of a natural gas explosion in Loudon County, Virginia, in 1998, the National Transportation Safety Board (NTSB) recommended (Recommendation P-01-002) that PHMSA require that excess flow valves be installed in all new and renewed gas service lines, regardless of a customer’s classification, when the operating conditions are compatible with readily available valves. Natural...

When we encounter a manufacturing facility that has been pulled into OSHA’s PSM or EPA’s RMP, we are almost certain to find the same design features for the emergency stop functions (i.e., E-Stops). Most of these facilities are shocked to learn there is a big difference between the location of an E-Stop on a machine or conveyor and one on a hazardous materials process. If we think about...

I believe in Excess Flow Valves and Check Valves, even though I have seen them fail more often than work as hoped. However, these failures are “human failures” in the incorrect design (e.g., sizing and placement) of the process where these valves are utilized. The valves are highly reliable when they are DESIGNED, INSTALLED, and TESTED per the manufacturer’s requirements/recommendations....

Some Excess Flow Valves (EXFVs) models can be placed into a position that would render them useless in their intended function. I have encountered this scenario more than once during my PHAs, Investigations, Audits, etc. There are not many manufacturers that incorporate this failure mode in their designs, but there a couple that do; and for those that do, I HIGHLY RECOMMEND these valves be placed into...